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10/10/2018 3:25 PM
Hidalgo County District Clerks
Reviewed By: Iris Ramirez
V E R IF Y | S
STATE
OF
DELAWARE
”00-proffl
Electronically Filed
10/10/2018 3:25 PM
Hidalgo County District Clerks
Reviewed By: Iris Ramirez
want of prosecution
Verifyis Foundation a tax exempt entity located in Delaware will now Bring Forth the forms of
action for a given cause D-‐1-‐GN-‐17-‐006662 per C-‐3360-‐18-‐C
Electronically Filed
9/6/2018
10/10/201812:45
3:25PMPM
Hidalgo County District Clerks
Reviewed By: Alexis Bonilla
Iris Ramirez
C-3360-18-C
No._______________________________
LINDSEY WHISENHANT
Plaintiff, R. M. FROST, files this original petition against said defendants and alleges as
follows
DISCOVERY-CONTROL PLAN
1. Plaintiff intends to conduct discovery under Level 2 of Texas Rule of Civil Procedure
190.3 and affirmatively pleads that this suit is not governed by the expedited-actions process
in Texas Rule of Civil Procedure 169 because plaintiff requests injunctive relief and seeks
monetary relief of $1,181,939.68
!! Pursuant to His wishes, The Applicant will speak in first person after filing a
master case in Travis County District Court D-1-GN-17-006662 12/13/17.
Any move to dismiss under 91a will result in the revocation of a Texas License
through the Disciplinary Council of State Bar and may conceive further litigation.
PARTIES
VENUE
6. Venue is mandatory in Hidalgo County under Texas Civil Practice & Remedies Code
section 15.017 because this suit involved criminal acts, and The Looting of a Decedent
Estate. This is the location of Stolen Monies.
FACTS
7.
•! Together they stole My Family’s Money after Mother and Grandfather both
died in 2014
•! They have had Four Years and Forty-Eight Months to bring My Capital
•! I’m having trouble sleeping every night with blood coming out of my surgery
and The Fear of What Will Be Done To Me
•! People come off the street to death threat me where I’m being held
•! Mr. Ciccone will not carry out his fiduciary duty by helping to take care of a
rundown property he stuck me in
•! He allows documents to sit at the Probate Court for many months until everyone
forgets about them Except Me
•! I have tried multiple times to get into contact with his colleague Ezequiel Reyna
only to realize he is Just As Bad
•! Lindsey Whisenhant will not respond to my phone calls or emails and he is the
de facto probate attorney for Mother and Grandfather in Woodville, TX
•! It was necessary to hire yet another attorney Philip Martin Ross who charges
high wages at $500/hr
•! Edward Ciccone has tried to hide his illegal activity by collateralizing two
different estates into one and pretending there are not any Written Documents to go
Off Of
COUNT 1
JURY DEMAND
8. Plaintiff demands jury trial and tenders appropriate fee with this petition
Electronically Filed
10/10/2018 3:25 PM
Hidalgo County District Clerks
Reviewed By: Iris Ramirez
CONDITIONS PRECEDENT
9. All conditions precedent to Plaintiff’s claim for relief have been performed or have
occurred.
REQUEST OF DISCLOSURE
10. Under Texas Rule of Civil Procedure 194, Plaintiff requests that defendant disclose
within 50 days of the service of this request, the information or material described in 194.2
11. Plaintiff objects to the referral of this case to an associate judge for hearing a trial on
the merits or presiding at a jury trial.
PRAYER
12. For these reasons, Plaintiff asks that the court issue citation for defendant to appear and
answer, and that Plaintiff be awarded a judgment against defendant for the following
a. Actual damages
b. $1,181,939.68
c. Exemplary damages
e. Court costs
f. Attorney fees
By:________________
RYAN M. FROST
7426 Dove Mountain
San Antonio, TX 78209
512-964-6835
Electronically Filed
10/10/2018 3:25 PM
Hidalgo County District Clerks
Reviewed By: Iris Ramirez
Defendant(s):
702 W Expy 83 # 100
Weslaco, TX 78596
Plaintiff:
7426 Dove Mountain
San Antonio, TX 78209